Data Protection Policy
1.1 This policy sets out RTC Sport’s approach to data protection and subject access
and the ways in which the organisation will safeguard the rights and best interests of all those on whom it holds data, by keeping secure, accurate and up-to-date records.
2.1 Data is defined by the Data Protection Act (1998) as information which:
(a) is being processed by means of equipment operating automatically in response
to instructions given for that purpose
(b) is recorded with the intention that it should be processed by means of such
(c) is recorded as part of a relevant filing system or with the intention that it should
form part of a relevant filing system,
(d) does not fall within paragraph (a), (b) or (c) but forms part of an accessible record as defined by section 68, or
(e) is recorded information held by a public authority and does not fall within any of paragraphs (a) to (d)
As a broad rule, the Information Commissioner’s Office (ICO) considers that a
relevant filing system exists where records relating to individuals (such as personnel records) are held in a sufficiently systematic, structured way as to allow ready access to specific information about those individuals. Data can be held
electronically or on paper.
2.2 The Data Protection Act (1998) also defines ‘personal data’ and ‘sensitive data’.
The definitions can be found on the ICO website:
3.0 Legal obligations
3.1 Within RTC Sports all data will be collected, processed, maintained, stored and
disposed of in accordance with the principles of good practice and according to the
Data Protection Act. This will ensure that all data is:
• fairly and lawfully obtained
• held for specified and legal purposes
• processed in accordance with an individual’s rights under the Data Protection Act
• adequate, relevant and not excessive in relation to those purposes
• accurate and up to date
• not kept for longer than is necessary for its given purpose
RTC Sports is a registered charity in England and Wales (1151355). Registered as
a company limited by guarantee in England and Wales No.5969860. Registered
office: RTC Sports Centre Otterburn Northumberland NE19 1LL.
• subject to appropriate safeguards against unauthorised use, loss or damage
• not transferred outside the European Economic Area unless the recipient country
has adequate data protection.
3.2 RTC Sports will nominate a Data Protection Officer. RTC Sports is exempt from
the requirement to maintain an up-to-date register entry with the Information
4.0 CCTV Security Surveillance System
4.1 RTC Sports uses a CCTV surveillance camera system on its premises, for the
safety and security of users and to protect premises and equipment against
4.2 Where necessary, images and information will be shared for law enforcement
5.0 Subject access to records
5.1 Where personal information is kept about an individual, they will have right of
access to it and be entitled to correct any error or omission in it.
5.2 People wishing to access data held about them by RTC Sports are required to
contact the Data Protection Officer, who will advise them of the procedure to be
5.3 Access to such data will only be refused under circumstances outlined in the
Data Protection Act, for example to maintain third party confidentiality.
5.4 Anyone with a complaint about the way RTC Sports keeps data about them is
referred to the Information Commissioner – details can be found at